The focus on Governance in the IORP Directive is welcome as it is designed to protect members and ensure good outcomes. We believe we already have a strong governance structure in Ireland through the trusteeship model, legislative and regulatory requirements. In order to implement the Directive in a manner that is proportionate we believe that the focus should be on building on the existing requirements. Any additional requirements will add to the overall cost of running schemes and that cost could ultimately fall on the members. There is also a possibility that additional regulation that employers and trustees view as excessively onerous relating to the operation of pension schemes could lead to employers exiting from this space entirely. This would be disadvantageous to members as any mandatory regime is likely to be less generous than the schemes presently in existence

The Directive allows Member States to take into account the size, nature, scale and complexity of a scheme in implementing many of the measures and this does not appear to be covered in the consultation. We would expect that the level of risk management required for a large scheme with tens or hundreds of billions in assets and liabilities to be very different to the average Irish scheme.Download this publication Click IAPF response to The Pensions Authority's Consultation on Key Function Holders to download 71KB

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